Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) describes how Rezo Nclusif Ltd, a company incorporated in England and Wales under company number 14908857, trading as “Bédoo” and “Bedoopay” (“we”, “us”, or “our”), collects, uses, discloses, and protects your personal data when you use the Bédoo application, website, and related services (the “Services”).

We are committed to protecting your privacy and handling your personal data in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as the EU General Data Protection Regulation (EU GDPR) where applicable.

By using the Services, you acknowledge that you have read and understood this Policy. This Policy should be read in conjunction with our Terms of Service.

2. Data Controller

The data controller responsible for your personal data is:

Rezo Nclusif Ltd

Company Number: 14908857

Registered in England and Wales

Email: privacy@bedoopay.com

Where our regulated partners (such as NOAH, Bridge, or mobile money aggregators) process your personal data in connection with services they provide directly, those partners act as independent data controllers and are subject to their own privacy policies.

3. Personal Data We Collect

3.1 Information You Provide Directly

• Identity Data: Full name, date of birth, nationality, and gender.

• Contact Data: Email address, telephone number, and postal address.

• Verification Data: Identity documents (passport, national identity card, or driving licence), selfie photographs, and proof of address documents, as required for KYC verification.

• Financial Data: Wallet addresses, transaction history, and beneficiary details.

3.2 Information Collected Automatically

• Technical Data: IP address, device type, operating system, browser type, unique device identifiers, and app version.

• Usage Data: Information about how you use the Services, including features accessed, pages viewed, session duration, and interaction patterns.

• Location Data: Approximate location derived from your IP address or, with your consent, more precise location data from your device.

3.3 Information from Third Parties

We may receive personal data about you from our regulated partners in connection with KYC/AML verification, transaction processing, and fraud prevention. We may also receive data from analytics providers and advertising networks.

4. Purposes and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

5. Sharing of Personal Data

We may share your personal data with the following categories of recipients:

• Regulated partners: NOAH, Bridge, and mobile money aggregators who provide banking, IBAN, and payment services. These partners process your data as independent data controllers under their own privacy policies.

• KYC/AML service providers: Third-party identity verification and compliance providers acting as data processors on our behalf or on behalf of our regulated partners.

• Technology service providers: Hosting, analytics, customer support, and communication providers acting as data processors under our instructions.

• Law enforcement and regulatory authorities: Where required by law, regulation, or legal process.

• Professional advisers: Lawyers, auditors, and insurers as necessary.

We do not sell your personal data to any third party.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area (EEA), including countries where our regulated partners, service providers, and infrastructure are located.

Where such transfers take place, we ensure that appropriate safeguards are in place in accordance with applicable data protection law, including:

• Transfers to countries with an adequacy decision from the UK Secretary of State or the European Commission.

• Standard Contractual Clauses approved by the relevant authority.

• Other lawful transfer mechanisms as permitted under applicable legislation.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or regulatory requirements.

• Account data: Retained for the duration of your account and for a period of 6 years following account closure, in accordance with UK regulatory requirements.

• Transaction data: Retained for a minimum of 5 years from the date of the transaction, in accordance with AML record-keeping obligations.

• KYC/Verification data: Retained for a minimum of 5 years following the end of the business relationship, as required by applicable AML regulations.

• Technical and usage data: Retained for up to 2 years.

• Marketing data: Retained until you withdraw your consent.

8. Your Rights

Under applicable data protection law, you have the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data we hold about you.

• Right to rectification: You may request that we correct any inaccurate or incomplete personal data.

• Right to erasure: You may request the deletion of your personal data, subject to our legal obligations to retain certain data.

• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances.

• Right to data portability: You may request your personal data in a structured, commonly used, and machine-readable format.

• Right to object: You may object to the processing of your personal data where we rely on legitimate interests.

• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time.

To exercise any of these rights, please contact us at privacy@bedoopay.com. We will respond to your request within one month, as required by applicable law. We may ask for additional information to verify your identity before processing your request.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) in the United Kingdom (www.ico.org.uk), or with the relevant supervisory authority in your jurisdiction.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and staff training on data protection.

While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal data.

10. Cookies and Tracking Technologies

The Bédoo website and Application may use cookies and similar tracking technologies to enhance your experience, analyse usage patterns, and deliver relevant content. For detailed information on the cookies we use and how to manage your preferences, please refer to our Cookie Policy available on our website.

11. Children’s Privacy

The Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete it as soon as possible.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. Material changes will be communicated to you through the Application or by email. The most current version will always be available at bedoopay.com/privacy.

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

Rezo Nclusif Ltd

Company Number: 14908857

Registered in England and Wales

Email: privacy@bedoopay.com

Website: bedoopay.com